In-Service Conformity Light-Duty Emissions Testing

A review by the European Commission of the historical light-duty emissions In-Service Conformity (ISC) tests, previously only performed by the manufacturers, revealed that very few ‘fails’ were reported to type approval authorities. This is despite known emissions-related recall campaigns and other voluntary actions being implemented in-market.

In an attempt to increase the effectiveness of ISC, and improve the correlation between a manufacturer’s ISC failure rates and in-market remedial actions, control has now also been given to Granting Type Approval Authorities (GTAAs) to perform ISC tests on a percentage of the approved vehicle emission types each year. The GTAA in this case is STA.

VCA and STA are responsible for selecting which vehicle types shall be tested each year for ISC. This is based on a risk assessment, supported by multiple data sources, to identify the vehicles that are most likely to “not comply with ISC rules”. This pertains to the vehicle exceeding one or more of the Euro 6 pollutant emissions limits, as given in Regulation (EC) No 715/2007, in Type 1, 4, 6 or RDE tests.

VCA and STA do not currently have the facilities in order to perform light-duty emissions tests required for ISC. As a result, VCA and STA are seeking the services of a Supplier with these facilities to perform this work.

Only Type 1 and RDE tests, as detailed in Annex IIIA and XXI, respectively, of Regulation (EU) 2017/1151, as amended by Regulation (EU) 2018/1832 (eur-lex.europa.eu/legal-content/GA/TXT/ ↗), will be included in the scope of this ISC testing.

The GTAA is required to publish an annual report which presents the results of all ISC testing conducted in the previous year, as well as all associated investigations therein (once closed). The deadline for submitting this report is 31 March of each year.

VCA and STA have identified 12 ISC families (i.e. vehicle types) that need to be tested for ISC purposes for the ISC 2020 annual programme. According to the regulation, a minimum sample size of three vehicles is required for each family (i.e. 36 vehicles total). However, the scope of this Contract is planned to exclude the testing of the first vehicle from each sample, as that activity has been awarded in a separate contract (subject to delivery). Therefore, a minimum of 24 vehicles are required to be tested by the Supplier who is awarded this Contract.

It has been decided to split the contracts in this way to commence the ISC 2020 testing as soon as possible, and allow for the “statistical folders” to be opened for each test type (see last paragraph in point 5.10.1. of Annex II,) before 31 March 2021. Once each folder has been opened, the GTAA has 12 months to complete all testing (with an extra 6 months if necessary), which is permitted to go beyond the 31 March date.